- 23 - before the liquidation. We disagree. That was before the last return for the years in issue was due from House of Babes. The Commissioner could assess tax for House of Babes' earliest taxable year in issue, 1984, at least until March 15, 1988, and beyond that if House of Babes committed fraud. Petitioners contend that imposing transferee liability on them is unlawful double taxation. We disagree. Respondent is trying to collect House of Babes' taxes; no prohibited double taxation is present here. Petitioners contend that section 6901(a)(1)(A) does not authorize respondent to collect an amount equal to 100 percent of the value of the property they received from House of Babes. We disagree. Respondent may collect the lesser of (1) the transferor's tax liability, including additions to tax and interest, or (2) the value of the assets the transferee received, plus interest. Peterson v. Sims, 281 F.2d 577 (5th Cir. 1960); Mysse v. Commissioner, 57 T.C. 680, 703 (1972). 3. Conclusion We conclude from the badges of fraud that are present here that House of Babes fraudulently intended (through its shareholders) to transfer its assets to its shareholders with intent to delay payment of its creditors. Harper v. UnitedPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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